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Article Summary
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper -- summary under Paragraph 7(1)(b)
CRA’s position is that the present value of the contingent payment must be included in income up front ….] ...
Article Summary
Nathan Boidman, "Canada Targets Conduits and Tracking Shares", Tax Notes International, September 17, 2018, p. 1223 -- summary under Subsection 95(9)
Instead, it must employ more than five individuals per business — therefore, more than 10 for two businesses…. ...
Article Summary
Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee -- summary under Subsection 212.3(26)
Ss. 212.3(26)(a) and (b) also are unnecessary – if the CRIC is controlled by a Canadian-resident trust (albeit, with non-resident beneficiaries), the CRIC will in reality be controlled by Canadian-resident decision makers. ...
Article Summary
Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Subparagraph 251.1(1)(g)(ii)
Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79-- summary under Subparagraph 251.1(1)(g)(ii) Summary Under Tax Topics- Income Tax Act- Section 251.1- Subsection 251.1(1)- Paragraph 251.1(1)(g)- Subparagraph 251.1(1)(g)(ii) Example of 2 trusts sharing a majority-interest beneficiary who are not affiliated (p. 28:18) … Canco, a corporation, is a majority interest beneficiary of both trust D and trust E and therefore should be affiliated with both trust D and trust E pursuant to subparagraph 251.1(1)(g)(i). ...
Article Summary
Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Paragraph 251(1)(b)
Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79-- summary under Paragraph 251(1)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(b) CRA application of s. 251(1)(b) (p. 28:52) The CRA considered the application of paragraph 251(1)(b) to a situation in which a person was a beneficiary of two different personal trusts and factually dealt at arm's length with each trust [fn. 120: … 2003-0038605]. ...
Article Summary
Marc André Gaudreau Duval, Michael N. Kandev, "Foreign Affiliate Issues in Troubled Times", International Tax (Wolters Kluwer CCH), No. 112, June 2020, p. 1 -- summary under Subsection 91(4)
. … [T]he result of deferring the payment of the foreign tax is that the FAT deduction will be reduced by four times the amount so deferred, thus potentially give rise to Canadian taxes. ...
Article Summary
Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper -- summary under Paragraph (g)
(g) of the interest and financing revenues definition of the relevant affiliate interest and financing revenues (“RAIFR”) of a controlled foreign affiliate of the taxpayer, is generally reduced by any deduction under s. 91(4) in respect of foreign accrual tax to the extent that it relates to the RAIFR, even where there is a deduction under s. 91(4) in a subsequent taxation year – so that taxpayers may be required to estimate their foreign accrual tax deductions that will be claimed in subsequent years. ...
Article Summary
Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter -- summary under Relevant Affiliate Interest And Financing Revenues
For example, where an interest-bearing upstream loan by a CFA to wholly-owning Canco is subject to Canadian withholding tax of 25%, this scenario is neutral from an EIFEL perspective since there is IFE (in Canada) and corresponding IFR (in a wholly-owned CFA) – yet, Canco would recognize IFE but no interest and financing revenues (IFR) since the RAIFR of the CFA would be fully offset by a FAT deduction, being the grossed-up deduction for the 25% Canadian withholding tax. ...
Article Summary
Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter -- summary under Subparagraph (c)(iii)
., $5M value) wholly owned subsidiary, Subco 25% of whose shares are purchased by a non-resident investor, thereby causing the entire Canco group to cease to qualify under the domestic exception – whereas if the non-resident investor instead subscribed for the shares of Subco indirectly through a Canadian resident subsidiary, then Canco’s excluded entity status would not be lost. ...